The opinion of the court was delivered by: Hon. Morrison C. England, Jr.
STIPULATION TO VACATE STATUS CONFERENCE; ORDER
Date: August 11, 2011 Time: 9:00 a.m. Ctrm: 7
The parties request that the status conference currently set for August 11, 2011, be continued to November 10, 2011, at 9:00 a.m., and stipulate that the time beginning August 11, 2011, and extending through November 10, 2011, should be excluded from the calculation of time under the Speedy Trial Act. The parties submit that the ends of justice are served by the Court excluding such time, so that counsel for each defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4.
The parties are in the process of discussing and negotiating the various plea offers in this case Each defendant will need time to consider his or her offer in light of the discovery. As such, the attorneys for each defendant need more time to prepare, which will include reviewing discovery, discussing that discovery with their respective clients, considering new evidence that may affect the disposition of this case, conducting necessary legal research and investigation, and then discussing with their clients how to proceed.
For the above-stated reasons, a continued August 11, 2011, further Status Conference will conserve time and resources for both parties and the Court. The parties stipulate and agree that any delay resulting from this continuance shall be excluded in the interests of justice, and the ends of justice in endorsing this stipulation through formal order outweigh the best interests of defendants and the public in a speedy trial. See 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(iv).
LIBERTYBELL LAW GROUP, P.C. By Gina Tennen, Esq. Attorney for Defendant Masod John Rahimi United States Attorney Dated: August 5, 2011 By Michael M. Beckwith Assistant U.S. Attorney SEGAL LAW GROUP Dated: August 5, 2011 By Vitaly Sigal, Esq. Attorney for Defendant Monsore Rahimi
GOOD CAUSE APPEARING, it is hereby ordered that: the Status Conference presently set for Thursday, August 11, 2011, at 9:00 a.m., be continued to November 10, 2011.
MORRISON C. ENGLAND, JR. UNITED STATES DISTRICT JUDGE
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